1. PURPOSE
1.1 This Code of Ethics and Conduct contains the way in which we, as Smollan, act and do business, as well as the key principles, which all Smollan employees are required to adhere to.
1.2 This Policy should be read in conjunction with the Global Anti-bribery and Corruption Policy.
2. BUSINESS PRINCIPLES
2.1 Smollan will conduct its business with integrity, discipline, passion in compliance with the law, and with respect for all our employees.
2.2 The Company will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not limited government officials, clients and brokers or their representatives. We will collectively ensure that all our staff understand this policy through training, communication and by example.
2.3 The Company is committed to working with employees to develop and enhance each individual’s capabilities and skills. We are further committed to diversity within the workplace where there is mutual respect and where all parties are responsible for the performance and reputation of the company, its clients and customers. Employees will be employed and promoted on the basis of their qualifications and abilities needed for the work to be performed.
2.4 We are committed to safe and healthy working conditions for all employees. We uphold human rights and respect any employee’s right to freedom of association.
3. PERSONAL CONDUCT
3.1 Employees must, at all times, comply with the applicable, relevant legislation, Smollan rules and its disciplinary code.
3.2 Smollan will not condone any activities in violation of the law or unethical business practice.
3.3 All actions and conduct should be carried out in a professional, honest, non-discriminatory and ethical manner. Employees should therefore always ensure the appropriate behaviour towards all stakeholders and act as custodians of Smollan in its entirety.
3.4 Accordingly, employees must ensure that their actions cannot be interpreted as being in contravention of the laws and/or legislation applicable. Employees who are uncertain about the application or interpretation of any laws, rules or legislation should refer the matter directly to their line manager.
3.5 Any act of dishonesty, including fraudulent behaviour, will be considered as a serious offence and Smollan will take whatever action it deems necessary, within its lawful constitutional rights, to protect its interests against any such acts committed against it, its shareholders or its customers/clients and suppliers.
4. CONFLICT OF INTEREST
4.1 Smollan expects that employees will perform their duties diligently, honestly, to the highest ethical standard and in the best interests of Smollan’s business.
4.2 Employees must not use their positions or any knowledge gained as a result of their positions for private or personal advantage, regardless of the circumstances.
4.3 If employees sense that a course of action they have pursued, or are presently pursuing, or are planning to pursue may result in a conflict of interest with Smollan or one its customers, they should immediately communicate all the facts to their manager.
5. PRIVACY AND CONFIDENTIALITY
5.1 An employee must treat Smollan’s information (and that of its clients and suppliers) as confidential and will neither take personal advantage of privileged information gathered during employment, nor enable others to do so.
5.2 All employees must respect all copyrights and other intellectual property protections, including those relating to software or hardware, trademarks, trade secrets and know-how.
5.3 All employees must comply with all data privacy laws relevant to the regions they operate in and the functions they perform.
6. INDUCEMENTS
6.1 Smollan has a zero-tolerance approach to bribery and corruption and is committed to conducting its business in a legal and ethical manner.
6.2 No person associated with Smollan, whether it be an employee, contractor or third party, shall accept discounts, hospitality, commissions, incentives or gifts as an inducement to show favour to any person or entity, or attempt to obtain advantage by giving financial inducement to a client or their employees.
6.3 No person associated with Smollan, whether it be an employee, contractor or third party, may accept entertainment or personal favours that could, in any way, influence, or appear to influence, business decisions in favour of any person or organisation with whom which Smollan has, or is likely to have, business dealings.
6.4 Similarly, no person associated with Smollan, whether it be an employee, contractor or third party, may accept any other preferential treatment under these circumstances because their positions with Smollan might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.
7. LAWS AND REGULATIONS
7.1 All employees are expected to comply with the laws and regulations of all relevant jurisdictions when conducting Smollan’s business.
7.2 No employee shall encourage another individual/employee to avoid applicable laws or regulations, the Smollan Code of Conduct (or any applicable policies), nor shall they condone any such violation.
8. FAILURE TO ABIDE BY THE CODE
8.1 Employees must make every effort to abide by this Code of Conduct, and all Smollan Policies.
8.2 It is the employee’s responsibility to report suspected incidents and/or violations to their manager or to a suitable escalations party.
8.3 Smollan retains the right to take appropriate action should an employee fail to abide by any elements of this code, of the policies. Such action may include warnings, dismissal or the institution of criminal charges where appropriate. Employees are referred to the Smollan Disciplinary Code in this regard.